Managing Regulated Medical Waste

Most states have developed comprehensive regulations regarding the on-site management of medical waste, although there are a few exceptions (e.g., MS, NE, and WY). The following summarizes the key aspects of these state rules.

Registration/Permits. State rules vary on requirements for registration. Some states do not have any registration process at all, while others require healthcare facilities to register (e.g., MI, SC) and in some states obtain a “generator identification number,” which is similar to a state RCRA hazardous waste ID number (e.g., RI,). In some cases, states differentiate between large and small quantity medical waste generators, where registration and other rules are less burdensome for the small facilities (e.g., 50 lbs/mth. limit in NC and SC, 60 lbs/mth. limit in OK, 200 lbs/mth. limit in CA and UT).

Some states require healthcare facilities to prepare a plan that ensures proper management of regulated medical waste (e.g., CA, NC, SC, UT, and WV). In some cases, compliance with this requirement is achieved by meeting planning requirements found in the OSHA Bloodborne Pathogen Standard.

Waste Segregation. Segregating regulated medical waste from general waste at its point of origin makes good economic sense for any healthcare facility because of the high costs associated with management and disposal of regulated medical waste vs. common office and municipal trash. In some states, segregation at the point of origin is required by law (e.g., MI, MT, and SC), in some other states, it is highly recommended (e.g., VT).

On-Site Transportation. Most states do have specific rules that apply to transporting regulated medical waste within a healthcare facility, although, in most states some general rules such as packaging, would apply. One state with specific internal transport rules is Rhode Island. In addition to packaging requirements, Rhode Island regulations cover mechanical aspects and disinfection of wheeled carts used for waste transport.

Packaging/Labeling. Specific rules for packaging and labeling of regulated medical waste vary by state, but in general, they are designed to safely contain the waste during storage and transport and to alert employees and the public to the potential hazard. Labeling is typically required prior to on-site storage or off-site transport.

Packaging requirements often include (check with your state agency for the specific rules that apply in your state):

• Generators must place and maintain all sharps in rigid, leak resistant, and puncture resistant containers which are secured tightly to preclude loss of the contents and which are designed for the safe containment of sharps; all other types of infectious waste must be placed, stored, and maintained before and during transport in a rigid or semi-rigid, leak proof container which is impervious to moisture.

• Containers must have sufficient strength to prevent bursting and tearing during handling, storage, or transportation. They must be sealed to prevent any discharge of the contents at any time until the container enters the treatment system.

• Plastic bags used inside of containers must typically be a red or orange color and have sufficient strength to prevent tearing.

• Infectious waste must be contained in disposable or reusable containers that are appropriate for the type and quantity of waste, must withstand handling, transfer, and transportation without impairing the integrity of the container, must be closed tightly and securely, and must be compatible with selected storage, transportation, and treatment processes.

• Reusable containers are usually acceptable, if they are disinfected after each use.

• Most states specify that medical waste containers may not be compacted.

Typical labeling standards require that receptacles containing infectious waste be clearly labeled with the biohazard symbol or with the words “Infectious Waste”. Some states require that labels also include the name of the generation facility, contact information and the destination facility (e.g., NC, WV).

Storage. Though regulated medical waste should be treated as soon as possible, some temporary storage is inevitable. Some states have very specific guidelines regarding storage areas and time limits. Most states do not require permits for waste storage. The following are typical requirements for storage (not all rules apply in every state):

• Regulated medical waste must be kept separate from other wastes in an area that is designated and clearly labeled with the universal warning sign or the word “biohazard.”

• The storage area must be ventilated and located to minimize exposure to the public and is accessible only to authorized personnel.
  • In some states carpets or floor coverings with seems cannot be used in storage areas (e.g., NY).

• Containers of regulated medical waste within the storage area must be prominently marked with the universal warning sign or the word “biohazard.”

• Floor drains must discharge to an approved sanitary sewer connection.

• Spill kits are required by some states (e.g., WV).

• There are often no maximum time limits for storage of RMW. However, the waste must be maintained in a nonputrescent state, using refrigeration, when necessary and vermin and insects must be controlled. Where storage time limits exist, they are in the range of 7 days (NY) to 90 days (AZ).

On-Site Treatment. In most states, regulated medical waste must be treated before it can be disposed of. Such treatment can be performed on-site or at an approved facility. Regulated medical waste treated on-site to render it non-infectious is usually no longer considered infectious for handling and disposal purposes (e.g., CO, MT, NV, SD) and in some cases, it may be mixed with and disposed of with ordinary waste when certain rules are followed (e.g., MT). However, many states require that treated waste remain segregated and often written notification must accompany the treated waste to its disposal location (e.g., CO).

All states allow healthcare facilities to treat regulated medical waste on-site when an approved method of treatment is used. Some states require permits or operating plans (e.g., NY) for the treatment units, while others only require air pollution permits for incineration units. Approved methods usually include incineration, steam sterilization (autoclaving), microwave sterilization, and chemical disinfection. Most states also have a process for granting permission to use new or alternative methods of treatment. This typically involves a petition process. Some states do not approve or recommend any specific treatment methods, but leaves it up to the generator to determine what is an appropriate and effective treatment method for their wastes (e.g., CO).

Liquids, including blood, but excluding chemical wastes, may be discharged to the sewer in many states, although local sanitary district approval is usually required (e.g., MO, MT, NC, OK, UT).

Training. All employees involved with the on-site management of regulated medical waste (i.e., packaging, labeling, storage, or treatment) must be trained in accordance with the requirements of the OSHA Exposure to Bloodborne Pathogens regulations (29 CFR 1910.1030). Some states have additional training requirements (e.g., MI).

Recordkeeping, Reporting and Tracking

Some states require that a tracking document be prepared before regulated medical waste is shipped off-site and that the document accompanies the waste to the treatment/disposal site in a manner similar to a RCRA hazardous waste manifest (e.g., MO, NY, RI, SC, WV). Where used, tracking documents are typically multi-copy forms where the generator, transporter, and disposal site retain copies and the disposal site returns a final copy to the generator once the waste is disposed of (e.g., MO).

In some states generators must maintain records of the quantity of regulated medical waste generated, and the disposition of those wastes (e.g., NY, NC). Also, some states require generators to submit annual reports indicating the quantity of regulated medical waste and its disposition (e.g., NY, WV).

Off-Site Transport

In nearly all states, transporters of regulated medical waste must have a medical waste transporter permit in order to pick-up, transport, or deliver regulated medical waste. Small volumes of regulated medical waste may be transported without a permit in some states.

Off-Site Treatment and Disposal

In most states, regulated medical waste must be treated to render it non-infectious before it can be disposed of. Such treatment can be performed on-site or at a permitted treatment facility. Permitted facilities have stringent standards that must be met.

Many states also have provisions that allow larger healthcare facilities to accept regulated medical waste for processing from smaller facilities (e.g., MO).

Some states allow the direct disposal by landfilling of untreated medical waste (e.g., Co, NV), although in these cases, specific rules must be followed (e.g., properly labeled and packaged infectious waste may be disposed on in a permitted solid waste disposal facility without treatment in Colorado) and the landfill must be approved for this kind of waste (e.g., CO).